The AEOI Implementation 2019 – The official report and practical experience

Over 100 jurisdictions committed to implement the AEOI and commence exchanges in 2017 or 2018. The OECD has analysed the status of implementation and published the  2019 AEOI Implementation Report . We would like to highlight some of the key figures and comment on how we at KENDRIS experience the progress of the AEOI implementation worldwide.

In a nutshell: 

• Information regarding 47 million financial accounts with a value of EUR 4.9 trillion exchanged in 2018
• Domestic and international legal framework in 98% of all participating jurisdictions in place
• Room for improvement in terms of an effective AEOI Standard implementation in many jurisdictions

Let’s start with the good news: in 2018, information relating to 47 million financial accounts with a combined value of around EUR 4.9 trillion was exchanged. The number of partner jurisdictions to which each jurisdiction sent information has increased by 36% from 2018 to 2019. In addition, 98% of all jurisdictions that committed to implement the AEOI have the domestic legal framework in place. Furthermore, 100 jurisdictions have the international legal framework in place, representing as well 98% of the committed jurisdictions. The international legal framework is comprised of a legal basis for AEOI and an operative level competent authority agreement that contains the details of the exchanges. There are still, however, a few jurisdictions that although asked to commit and exchange data pursuant to the AEOI Standard in 2018, are yet to commence their first exchanges. Reviews are being conducted in order to ensure an effective AEOI Standard implementation in all jurisdictions based on a level playing field. The respective effectiveness ratings will be issued in 2021.

As part of our   CRS services , we take care of CRS filings for  financial institutions  in many different AEOI jurisdictions and we are therefore aware that in some jurisdictions there is room for improvement in terms of an effective AEOI Standard implementation. Not all jurisdictions that implemented the AEOI have been able to adapt their local legislation to an international audience and put in place the required infrastructure. In particular, we have experienced difficulties with registering financial institutions, with reporting portals that are working or not available on time, and with obtaining the sufficient assistance from local authorities in dealing with such cases. On the other hand, in other jurisdictions, we experience that the authorities are now getting up to speed with analysing the received data and are starting to ask questions.

The 2019 AEOI Implementation Report clearly shows that the standard already has a significant impact. However, the authorities and the reporting financial institutions are still on a learning curve, and we expect the quantity and quality of the exchanged information to increase further in the coming reporting periods. We also expect authorities to take a more active role in following up on the reported data.

Please get in touch with our  CRS & FATCA experts  if you experience difficulties with your CRS( Common Reporting Standard ) reporting or are interested in our  CRS reporting services  , or if you have any other questions on this subject.